[EAS] Comments on FCC 21-77 on FEMA requested changes to EAS

[Sean Donelan]

Comments submitted by 5 people/organizations

Adrienne Abbott, Nevada SECC Chair
Paul Davis, Xperi Holding Corporation
Sean Donelan, individual capacity
Rick Kaplan, et al, National Association of Broadcasters
Harold Price, Sage Alerting Systems

All submitted comments about Persistent Alerts.  Smattering of comments 
on the other questions. FCC often cherry-picks comments supporting what 
they already decided.

Lots of good information and justifications in the submissions. Read the 
actual submissions for the details. Overly simplified and summarized as 
follows:

1.	FEMA recommends the originator (ORG) code "Primary Entry Point 
System," ORG Code "PEP," should be changed to "National Authority," ORG 
Code "NAT."
a.	Adrienne Abbott, Nevada SECC Chair - Opposes changing ORG code, 
notes public doesn't understand PEP code
b.	Harold Price, Sage Alerting Systems - Opposes changing ORG code, 
Can change text
c.	Sean Donelan, individual capacity - Opposes changing ORG code, Can 
change text, Restore EAN ORG code for use by non-presidential authorities

2.	FEMA recommends that the definition for event code EAN be either 
changed to "Emergency Alert, National" or replaced with "National 
Emergency Message," event code "NEM."
a.	Harold Price, Sage Alerting Systems - Opposes changing EEE code, 
Can change text
b.	Sean Donelan, individual capacity - Opposes changing EEE code, Can 
change text

3.	FEMA recommends deleting the term National Information Center 
(NIC) in EAS rules.
a.	Harold Price, Sage Alerting Systems - Not opposed to deleting NIC 
event code
b.	Sean Donelan, individual capacity - Repurpose NIC event code for 
national alerts

4.	FEMA recommends changing the WEA alert category "Presidential" to 
"National" alerts.
a.	Previous WEA rulemaking

5.	FEMA recommends that State Emergency Communications Committee 
(SECC) functions be aligned with Statewide Interoperability Coordinator 
(SWIC) functions and that State EAS Plans be incorporated into Statewide 
Communication Interoperability Plans.
a.	Previous rulemaking

6.	FEMA recommends the FCC consider methods to update the EAS to 
support persistent display of alert information and/or persistent 
notification for emergencies that require immediate public protective 
actions to mitigate loss of life.
a.	Adrienne Abbott, Nevada SECC Chair - Opposes, let the local 
broadcasters do what they do best
b.	Harold Price, Sage Alerting Systems - Opposes
c.	Paul Davis, Xperi Holding Corporation - Supports, some HD radio 
models have alert history
d.	Rick Kaplan, et al, National Association of Broadcasters - Opposes
e.	Sean Donelan, individual capacity - Opposes, notes some consumer 
devices have alert history, suggests a non-routine "Cancel Alert" event 
code